In South Carolina (and other jurisdictions), appellate briefs begin with a Table of Contents. The Table’s obvious purpose is to tell the reader where to find the various parts of the brief. In that vein, headings may be used in the Statement of Facts, and repeated in the Table of Contents, to give sign posts through the story or narrative.
Argument headings can do more. They may be used to achieve the greater aim of persuading the reader why you should win. Continue reading